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C. Respondent’s Notice of Determination and Form 4340
On May 18, 2001, respondent sent to petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (the lien or levy determination) in which respondent
determined to proceed with collection from petitioner of her tax
liability for 1996.
On March 31, 2002, respondent’s counsel sent petitioner a
Form 4340, Certificate of Assessments, Payments, and Other
Specified Matters, relating to petitioner’s 1996 tax year.
OPINION
A. Whether Respondent Improperly Precluded Petitioner From
Disputing Her Underlying Tax Liability for 1996
Petitioner points out that she did not timely receive a
notice of deficiency and contends that respondent improperly
refused to permit her to dispute her underlying tax liability for
1996 at the hearing with Iwane. We disagree; the Appeals officer
did not prevent petitioner from disputing the amount or existence
of her underlying tax liability for 1996 at the hearing. Iwane’s
refusal to consider petitioner’s frivolous arguments does not
constitute a refusal to permit petitioner to contest her
underlying tax liability.
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